Unites States of America v. Apple, Inc. et al

Filing 186

Letter addressed to Judge Cote from Amazon.com, Inc. (Michael Kipling) dated 2/19/2013 re: Apple/Amazon discovery dispute. Document filed by Amazon.Com, Inc. (Attachments: #(1) Exhibit Zapolsky Decl., #(2) Exhibit A, #(3) Exhibit B, #(4) Exhibit C) (cr)

Exhibit B

1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------x
UNITED STATES OF AMERICA,
Plaintiff,
vs.

CASE NO.
12-CV-2826(DLC)

APPLE INC., et. al,
Defendants.
--------------------------------x
HIGHLY CONFIDENTIAL
VIDEOTAPED DEPOSITION
DAVID NAGGAR
JANUARY 30, 2013
1918 Eighth Avenue
Seattle, Washington

REPORTED BY:
PAUL J. FREDERICKSON, CCR, CSR
JOB NO. 28641

DAVID NAGGAR - HIGHLY CONFIDENTIAL
114
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116
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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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DAVID NAGGAR - HIGHLY CONFIDENTIAL
The decision that Amazon was not that interested

"But Amazon may make more money with its model."

3

11:07:11

in an agency model, that was made by Mr. Bezos

3

Do you see that?

4

previously?

4

A. I do.

MR. SUTTON: Objection.

5
6

11:08:58

A. No, it was made in a group setting with --

5

Q. Do you believe that that -- that that's

6

true, that Amazon may make more money under the agency
model than it had been under the reseller model?

7

Mr. Bezos was there but it was several of us

7

8

discussing the options with our lawyers.

8

MR. FRIEDMAN: Object to form.

9

MR. KIPLING: Object to form.

9
11:07:24

Q. And it was made earlier in the week?
MR. KIPLING: Objection.

10
11
12
13

MR. SUTTON: Object to form.

10

Which week are you talking about?

11

BY MR. PARKER:

12

A. I don't know under this specific proposal.
BY MR. PARKER:

13

14

has testified he went to New York and said that Amazon

15

wasn't interested in the agency model.

looked at the economics of agency, whether from an

15

economic point of view it might be in Amazon's interest

16

A. Yeah.

16

to actually agree to the agency model?

17

11:07:31

Q. And I assume you were authorized by top

17

A. I just want to clarify something.

18

Q. Please.

18
19

management to say that; am I right?
A. Yeah, I -- I don't remember when we

20

Russ and I discussed. I don't remember.

22
23
24
11:07:56

19

discussed it with Jeff. This may have been something

21

11:07:41

11:09:25

Q. Had Amazon ever looked at that, that is

14

Q. Well, what I'm referring to is the witness

25

11:09:36

20
21

A. You're referring to the agency model as a
monolithic uniform model.
You can see that in his email he's offering a 5

Q. Okay. All right.

22

percent commission on best sellers and a 20 percent

The second to last paragraph, the last sentence

23

commission on back list.

24

says:
11:09:48

"I assume this agency model will change where

Q. Right.

25

A. Which is a very different economic

115
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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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DAVID NAGGAR - HIGHLY CONFIDENTIAL

2

2

proposition from a 30 percent commission across the

3

less on the back list, but you may make more money with

3

board.

4
11:08:10

you earn your margin, more margin on best sellers and

this model."

4

Q. Which is what you ultimately agreed to, 30

5

Do you see that?

6

A. I do.

6

A. With HarperCollins, yes.

7

Q. Is that a true statement, in your judgment?

7

Q. Yes. All right.

8
9
11:08:20

10

11:09:56

MR. KIPLING: Object to the form.

8

Go ahead.
A. I -- I don't know. Can you clarify a

5

9

percent?

Did you -- did Amazon -- okay, that's a very
good point.

10

Did Amazon ever do an analysis of the economics

11

little bit for me?

11

of the agency model under any assumption, of commission

12

BY MR. PARKER:

12

or whatever?

13

11:10:06

14

model would you make more margin on the best sellers

14

15

and less on the back list? Is that something you -- is

16

11:08:29

Q. Well, my question is that under the agency

13

that a true statement?

17

11:10:21

15

A. I don't remember seeing a specific
financial analysis.

16

Q. Did you have -- had you seen any analysis

17

MR. FRIEDMAN: Object as to form.

that suggested that under certain assumptions Amazon
might make more money under the agency model?

18

A. I don't know. It is -- it is probably

18

19
11:08:44

MR. SUTTON: Objection.

true on best sellers. I don't know that it's true on

19

20

back lists.

11:10:37

20

MR. SUTTON: Objection.
A. Not that I recall. I don't remember any

21

Q. Okay.

21

specific analyses.

22

And it says but you -- and you understand "you"

22

BY MR. PARKER:

23
24
11:08:51

23

to be Amazon. Am I right?
A. Yes.

25

Q. The way you interpret the document.

Q. Wouldn't that be a logical thing to do?

24
11:10:47

MR. SUTTON: Objection.

25

MR. KIPLING: Object to form.

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Q. What are his duties and responsibilities?

Q. I mean, why would you reject it without

3

A. He is a lawyer at Amazon.

4

Q. Business lawyer?

looking at the economics?

5

MR. KIPLING: Same objection.
MR. SUTTON: Objection.

7

11:12:34

5
6

A. We're very focused on the customer

7

8

experience first and foremost. Build a great customer

8

9

experience, and customers will respond to it by

9

10

engaging in your service. And our strong feeling was

11

that the customer would not be benefited by a move to

11

12

11:11:08

an agency model.

12

11:12:42

13

Q. Because?

14
11:11:23

A. They would pay higher prices.

15

Q. There would be no windowing. Isn't that a

16

DAVID NAGGAR - HIGHLY CONFIDENTIAL

A. I don't know.

6

11:10:58

120

10

13
14
11:12:48

15
16

benefit?

MR. FRIEDMAN: Objection to form.
A. I'm not sure I understand that term.
BY MR. PARKER:
Q. Was he working with you on negotiating the
agency contracts?
A. At the time we were not negotiating agency
contracts.
Q. But at the time you did, was he working
with you on those contracts?
A. Yes, he was.
Q. I mean, some lawyers work on litigation and
some lawyers work on --

17

17

MR. KIPLING: Objection to form.

18

Q. -- on contracts. He was more of a person

19
11:11:31

MR. SUTTON: Objection.

18

A. There was -- that is not a standard part

19

who would work on transactions and contracts --

20
21

the agency model that there be no windowing.

11:12:58

20
21

Q. No. But in connection with your

22

negotiations on the agency model, you got agreements

22

23

that there wouldn't be any windowing. Am I right?

23

MR. SUTTON: Objection.

24
11:11:41

25

A. Oh, I see.

MR. SUTTON: Objection.
MR. FRIEDMAN: Object to the form.
Q. Contracts the like; am I right?
A. In my dealings with him, it was around

24

A. I -- I believe you are in most cases.

11:13:04

contracts. I don't know the rest of his

25

responsibilities.

119

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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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2

Q. Thank you.

3

A. Yes.

3

David Zapolsky?

4

Q. Okay.

4

A. Yes.

5

Now, you talked about a meeting and you can't

5

Q. Who is he?

6

remember exactly when it was. Was it -- was it before?

6

A. Another lawyer at Amazon.

7

Do you think it was before your trip to New York or

7

8

11:11:54

Q. And that's a benefit to customers; right?

after?

8

9

A. The meeting I was referring to earlier?

A. I actually don't know. I mean, I know he
was a lawyer that was in many of our meetings but I

A. It would have been after.

11

don't know what his specific job duties were.

Q. Okay.

12

Q. You didn't then and you don't now?

You can't remember a date?

13

A. Now I know.

A. No, that's the one that was right after

14

Q. And what does he do now?

15

A. Now he is general counsel.

Q. Yes, sir.

11
12
13
14
15

9

Q. And what were his responsibilities as far
as you know?

10

10

11:12:12

11:13:07

the John Sargent visit.

11:13:17

11:13:27

16

16

Q. Now he is a general counsel.

17

A. January 28.

17

And approximately when did that happen?

18

Q. All right.

18

A. A few months ago, I believe.

19

And so Tim Leslie was there?

19

Q. Okay.

20

A. Yes.

20

Very recently?

21

Q. All right.

21

A. Very recently.

22

And who is Mr. Leslie?

22

Q. Okay. Great.

23

A. An AGC at Amazon.

23

Michelle Wilson. She is a lawyer?

24
11:12:26

Q. Got it. Right.

Q. I'm sorry, I don't know what --

24

A. She was general counsel at the time.

25

A. Associate general counsel.

25

Q. Okay.

11:13:34

11:13:40

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11:13:47

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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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with something else that's permitted that doesn't invade

A. I don't know her status with the company.

3

the privilege.

4

BY MR. PARKER:

She is snow longer general counsel.

5

Q. All right.

6

Mr. Bezos was there?

6

7

A. Yes.

7

8

Q. Mr. Kessel was there?

8

9
11:13:54

DAVID NAGGAR - HIGHLY CONFIDENTIAL

1

So she has now left the company, Ms. Wilson?

A. Yes.

10

12

5

Q. All right. What -- were there business
decisions that came out of this meeting?
A. Not as distinct from asking for lawyers'
counsel as to what we could do.

9

Q. Laura Porco was there?

11

11:15:17

Q. Did you come up with a business strategy

10

for dealing with proposals by Mr. -- such as that

A. Yes.

11

presented by Mr. Murray and others?

Q. And you were there?

12

13

A. Yes.

13

14

Q. And Mr. Grandinetti was there?

15

A. Yes.

16

Q. All right.

16

So at that meeting did anybody outline the pros

17

11:15:32

14
11:15:46

15

MR. KIPLING: You can answer yes or no to
this.
A. No.
MR. SUTTON: Objection.
BY MR. PARKER:

17

Q. So what did you come up with?

18

and cons to Amazon of going to the agency model?

18

MR. FRIEDMAN: Objection.

19

MR. KIPLING: I'm going to object and

19

20

instruct the witness not to answer about what was

21

11:14:12

discussed in the meeting.

11:15:51

20

MR. KIPLING: That -- instruct him not to
answer.
You can ask him about what he did after the

I've conferred with him and it was in his view and

22

meeting and what Amazon did after the meeting.

23

in my view a meeting at which legal advice was being

23

MR. PARKER: Oh, I'm about to.

24
11:14:25

21

22

sought and delivered by the lawyers for the company.

24

MR. KIPLING: Okay.

25

MR. PARKER: But I'm just asking.

25

THE WITNESS: That's correct.

11:15:56

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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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BY MR. PARKER:

2

DAVID NAGGAR - HIGHLY CONFIDENTIAL
BY MR. PARKER:

3

Q. Were you personally seeking legal advice?

3

Q. Was there any strategy of any kind that

4

MR. KIPLING: He -- I'm not suggesting that

4

came out of this meeting, strategic decisions for

5

Amazon?

he was. I'm suggesting that Amazon was seeking legal
advice. That's my client. And on that basis I'm

6

7

instructing this employee of Amazon not to answer the

7

And you can answer yes or no.

8

question.

8

A. No.

9
11:14:42

5
6

11:14:31

BY MR. PARKER:

9

10

Q. Was there any --

11:16:04

11:16:15

MR. KIPLING: Object to the form.

Q. So how did you leave it when you left?

10

Were you going to have another meeting or were you

11

MR. PARKER: I mean, Mike are you going to

11

going to continue thinking about it or --

12

block me on any question here? I mean, I can't ask any

12

A. Yeah. We -- there is no definitive

13

question whatsoever?

13

14

MR. KIPLING: You've spent 20 minutes asking

15

him questions about this meeting which has probed who was

16

11:14:53

there, when it happened.

17
18

THE WITNESS: Okay?
A. Not in that meeting, no.

MR. KIPLING: How long it was, whether

18

Q. There was at another meeting?

20

exhausts what you're permitted to inquire about in a

19
11:16:43

MR. PARKER: All right.

yeah, I am. Beyond what you've done, unless you come up

not at the meeting where the decision was made.

By -- who informed you?

24
11:16:51

Q. Okay.

23

MR. KIPLING: So beyond that I guess I --

25

were pulling the buy buttons from Macmillan but I was

22

Well, I'm --

24

A. At some point later I was informed that we

20
21

meeting that's privileged.

23

Q. Was there a decision to pull the buy
buttons on the Macmillan products on the Amazon site?

17

documents were prepared, which I believe pretty much

22

15
16

21

11:15:10

11:16:27

decision when I left the meeting.

MR. PARKER: Right.

19
11:15:02

14

A. Russ.

25

Q. What did he say?

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DAVID NAGGAR - HIGHLY CONFIDENTIAL
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buttons on the Macmillan books."

idea or did you agree with it or express any opinion at
all?
MR. SUTTON: Objection, form.

7

9
11:17:09

13
14
11:17:19

15

MR. KIPLING: I think he is, too.
THE WITNESS: I think I --

9

Q. Did he ask for your opinion as to whether
11:18:48

get back to question and answer form.
BY MR. PARKER:

10

Q. You said earlier you understood why Amazon

A. Not at that point, no.

11

was pulling the buy buttons on Macmillan, four or five

Q. Did you express your opinion on whether

12

questions ago. What -- why were they doing it?

13

A. No. We had things to execute at that
point.

11:19:03

A. To show to what level we felt that moving

14

that was a good strategy or not?

to an agency model was not a model we wanted to move

15

to.

16

Q. You just executed?

16

17

A. At that point, yeah.

17

18

Q. All right.

18

19
11:17:28

MR. KIPLING: This is argumentative. Let's

8

that was a good strategy or not?

11

MR. FRIEDMAN: Objection to form.

7

A. No, I understood why we were doing it.

10

12

11:18:43

5
6

5

8

A. Right.

4

Q. Did you tell him that was not a very good

6

DAVID NAGGAR - HIGHLY CONFIDENTIAL
buttons on Macmillan.

3

4
11:17:00

1

DAVID NAGGAR - HIGHLY CONFIDENTIAL
A. He said, "We're going to buy pull the buy

2
3

128

At any point did you express an opinion to

19

MR. SUTTON: Objection.
A. I don't believe we picked on Macmillan at

on Macmillan was a good idea?

11:19:10

A. I'm --

all. I believe Macmillan came out, presented a set of
terms of sale, presented us with an ultimatum, and

22

Mr. Grandinetti as to whether pulling the buy buttons

21

20
21

20

22

Q. You picked on Macmillan because they were
the smallest publisher?

threatened us with an inability to offer customers new

23

23

releases if we didn't acquiesce to a move to an agency

24
11:17:37

MR. KIPLING: I'm going to instruct him not
to answer what was discussed at the meeting with the

24

model.

25

general counsel of the company. But other than that, you

11:19:26

25

Q. So why didn't you do it to everybody else

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DAVID NAGGAR - HIGHLY CONFIDENTIAL

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2

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BY MR. PARKER:

3

4
11:17:48

can seek an answer.

Q. Go ahead.

4

5

A. No. I mean, we discussed how we would

11:19:34

5

6

respond to being forced into a model we didn't like.

6

7

Removing buy buttons was one option.

7

8
9

A. I think it was the right move.

10

Q. It was a disaster, wasn't it?

11

11:18:05

8

Q. Do you think it was a good idea?

MR. SUTTON: Objection.

9
11:19:43

10
11

DAVID NAGGAR - HIGHLY CONFIDENTIAL
too?
A. No one else had presented us with the
ultimatum at that point.
Q. You wanted to make an example out of
Macmillan?
MR. SUTTON: Objection.
A. No, we were responding to the specific
offer that Macmillan had put in front of us.
Q. What signal were you trying to send to the
marketplace?
MR. SUTTON: Objection.

A. No.

12

13

Q. Did customers like it?

13

MR. KIPLING: Object to the form.

14

A. No.

14

A. I don't believe we were trying to send a

12

15

signal. We were dealing with a very specific

16

when the buy buttons on Macmillan were pulled?

16

instance.

17

11:18:13

A. No. Which is exactly why it was such a

17

15

18

Q. Did that create a good customer experience

11:19:51

hard decision.

18

Q. How did that work out for Amazon?
MR. FRIEDMAN: Objection, form.
A. Can you be more specific.

19

19

20

A. The decision was made anyway.

20

21

11:18:24

Q. You made the decision anyway.

Q. Even if it was a bad experience for

21

Q. Well, did it end up being a good strategy

22

for Amazon? Did it achieve any business objective by

23

doing that?

22
23

customers in that -- in that instance?
A. In the -- in our opinion moving to an

24
11:18:37

Q. No, no. I'm talking about pulling the buy

24

agency model was a worse experience for customers.

25

BY MR. PARKER:

11:20:08

MR. KIPLING: Object to the form.

25

A. It's hard to say. We wound up with a

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negotiated contract with Macmillan a week later. That

2

3

was the end result.

3

So let's look at this document while you were

4

out of the room I marked as Exhibit No. 7, an email.

4
11:20:16

5

Q. Sitting here today looking back on it, was
that a good idea, pulling the buy buttons on Macmillan?

5

And you said you've seen it. Can you identify these

6

MR. FRIEDMAN: Object to form.

6

emails, sir?

7

MR. KIPLING: Object to the form.

7

8

MR. SUTTON: Objection.

8

myself, Russ Grandinetti, Steve Kessel and Tim Leslie

9

about a conversation with Brian.

9
11:20:26

11:26:13

Q. All right.

A. I believe it was the right decision.

10

Q. You still do?

11

A. Yes, I do.

11

12

Q. All right. Okay.

12

MR. PARKER: Let's do the next document.

13
14
11:20:36

14

MR. PARKER: Oh, okay. All right. Fine.

11:26:45

We'll just do the tapes right now.

15
16

Q. Okay.
And so the bottom email is one from Kessel to
Grandinetti and David Naggar saying:
"Let me know how the calls go today."
Were you instructed to make calls to the
publishers on January 25 of '10?
A. We were either making or receiving phone

17

THE VIDEOGRAPHER: Here marks the end of disc

17

10

13

[Discussion off the record.]

15
16

11:26:26

A. Yes. It is an email thread between

calls from publishers in followup to their -- the
meetings the previous week in New York.

18

number one in the video deposition of David Naggar.

18

19

Going off the record. The time is 11:21.

19

Q. And what can you remember about what you

20

[Recess at 11:20 a.m.]

21

[Resuming at 11:25 a.m.]

21

22

11:21:05

[Deposition Exhibit 7 marked.]

22

it would be a very poor customer experience for us to

23

move to an agency model, that we didn't feel that

24

publishers were prepared to take on pricing. None of

25

them had hired any staff or done any other work to be

THE VIDEOGRAPHER: Here marks the beginning

23
24
11:25:10

11:26:58

of disc number 2 in the continuing video deposition of

25

David Naggar. Back on the record. The time is 11:25.

11:27:20

20

were communicating to the publishers?
A. We were continuing to voice our view that

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2

books in a digital environment, where it should be

4

BY MR. PARKER:

prepared to handle consumer pricing for thousands of

3

EXAMINATION CONT'G

2
3

133

dynamic. And that we didn't feel we wanted to move to

5

an agency model.

4
5

could not inquire about what happened at the meeting

6

but I can inquire about what you did coming out of the

6

Q. Did you commence discussions nonetheless

7

11:25:19

Q. We were talking about this meeting, and I

meeting.

7

about what an agency model might look like at this

8

time?

8
9
11:25:27

11:27:33

And so the question is, tell me what you did

9

coming out of the meeting.
MR. SUTTON: Objection, form.

10

11:27:45

A. No. We were mostly in listening mode,

10

hearing what the publishers were going to put in front
of us.

BY MR. PARKER:

11

12

Q. Go ahead.

12

13

A. Yeah. I -- we left the meeting without

13

agency at that time?

11

Q. And in a mode of resisting the move to

14
11:25:42

making any final determinations as to what next steps

14

A. Correct.

15

were. So I was really just waiting for a next step.

15

Q. All right.

16

Q. So you were just waiting for instructions?

16

17

A. Sure.

17

Q. Is it fair to state the meeting you're

18

18
19

right?

21
22

Q. Brian being Brian Murray?
A. Brian Murray, yes.

22

came out, yes.

20
21

11:28:06

A. I -- if that's the date that John Sargent

the document says. So Brian Murray.

Q. All right. Okay.

23

Q. Okay.

23

24
11:26:02

A. I know it more in relation to that event

24

25

than the calendar.

A. Just got off the phone with Brian, is what

19

talked about was on the 28th of January? Is that

20

With whom did you speak on January the 25th, you
personally?

11:28:14

25

And please describe your conversation with
Brian.
A. Aided by the email, because I don't

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450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099

DAVID NAGGAR - HIGHLY CONFIDENTIAL
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2

136
1

remember the specific conversation.

DAVID NAGGAR - HIGHLY CONFIDENTIAL

2

there was a document being prepared for Mr. Bezos

3

setting forth the pros and cons of Amazon moving to the

4

agency model?

5

going to be part the Apple announcement. Didn't seem
to be wedded to specific agency models. He was

6

A. I have no recollection of such a document.

7

willing to look at various options or at least he led

7

Q. You've never heard of it?

8

me to believe he had the ability to mix and match his

8

A. I have no recollection of such a document.

9
11:28:40

3

A. He was still unsure of whether they were

6

11:28:23

Q. Right.

4

model.

9

Q. Okay.

10
11

Q. And what did you communicate to him about

11:30:42

11:30:51

5

10

MR. SUTTON: Objection, form.

Was there -- setting aside a document. Were you

11

your position?
A. That we were still very strongly objecting

assigned to come up with a presentation, whether orally

12

or written, about the pros and cons of the agency

13

to an agency model.

13

model?

14

Q. Did you --

14

A. No, I was not.

15

A. And we didn't want to go there.

15

Q. Do you know whether anybody was?

16

Q. Did you give him any hope there might be

16

A. No, I don't.

17

some compromise here that you might be able to work

17

Q. Could you see personally any benefit to

18

out?

18

Amazon going to the agency model as of the 25th of
January?

12

11:28:49

11:31:11

19

A. No.

19

20

Q. You did not. All right.

20

A. No.

21

11:28:57

And it's on the 25th of January you got to work.

21

Q. Okay.

22

Did Mr. Grandinetti advise you that the day before he

22

23

attended a meeting with Mr. Bezos in his boathouse?

23

we described, and shortly thereafter you, Amazon,

24

pulled the buy buttons on Macmillan; correct?

25

MR. SUTTON: Objection, form.

24
11:29:16

A. I have no knowledge of such a meeting.

25

Q. Did he simply tell you that he had met with

11:31:52

So on the 28th you had a meeting with the people

135
1
2

137

DAVID NAGGAR - HIGHLY CONFIDENTIAL

1

Mr. Bezos and others over that weekend?

2

3

3

Q. He never mentioned it to you at all?

4

5

A. He did not.

5

6

11:29:25

A. He did not.

4

Q. And so how did you know -- he came in and

6

7

said, "Look, what we've got to do is call these

7

8

publishers and continue discussions"?

8

9

DAVID NAGGAR - HIGHLY CONFIDENTIAL
A. The next day.
Q. And you were personally involved in
executing that strategy?
A. Yes.
Q. What did Mr. Grandinetti tell you about why
you were doing that?
MR. SUTTON: Objection, form.

9

A. Well, there was no difference in our

A. We were taking them down because they had

10

stance from the week before, which was we were very

10

presented us with an ultimatum and terms we couldn't

11

much against agency and we were looking to find out

11

live with and told us we had no option but to go with

12

what the publishers were going to do and how far they

12

those terms.

13

11:29:36

were going to push it.

13

14

11:32:10

Q. Okay.

14

Q. And if you didn't go with those terms, what
did Mr. Sargent say would be the consequences?

15

A. Well, he said, "You have a choice. You

16

people at Amazon were preparing a document setting

16

can either go to the agency model or you cannot see

17

11:29:47

forth pros and cons of the agency model for Mr. Bezos?

17

new releases for seven months."

15

18

Isn't it a fact that you told Mr. Murray that

MR. SUTTON: Objection.

19
20

Q. Were you the only one that had a

18

conversation that day with Mr. Murray?

11:32:43

Q. It was, I'm sorry, seven months?

19

A. Not to my knowledge.

21

11:30:15

11:32:31

A. I believe it was seven months, yes.

20
21

Q. So it was sign up with the agency model or
windowing; am I right?

22

22

A. Yes.

Q. Do you know if Mr. Grandinetti did?

23

Q. All right.

24
11:30:26

A. I don't know.

23

A. I do not.

24

25

Q. Was it the truth that internally at Amazon

11:32:54

25

How long were the buy buttons pulled on
Macmillan titles?

35 (Pages 134 to 137)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099